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The End of Modified Customer Interface (MCI) as Primary Open Banking Interface

End of Modified Customer Interface as Primary Open Banking Interface

On November 29, 2021, the Financial Conduct Authority (FCA) published a Policy Statement on “Changes to the SCA-RTS and to the guidance in ‘Payment Services and Electronic Money’”, which provides information on the use of a Modified Customer Interface (MCI) following industry consultations. 

MCI Cannot Be The Primary Interface for Open Banking 

In its Policy Statement, the FCA has confirmed that banks, Electronic Money Institutions (EMIs) and Payment Service Providers (PSPs) should put in place an application programming interface (API) solution by May 2023. However, some smaller institutions (as the ones presented below) are allowed to use MCI as Primary Interface: 

  • Small EMIs (SEMI) 
  • Smaller Payment Institutions (SPI) 
  • Passported Firms relying on Temporary Permissions Regime (TPR) and Supervised Run-Off regime (SRO) 

The FCA provided an 18-months implementation period, which is aligned with the time originally provided for the UK-SCA-RTS open banking changes. The latest version of the UK-SCA-RTS provides an update to Article 31. 

Modified Customer Interface

MCI as Fallback Interface to Dedicated API Interface 

Nonetheless, ASPSPs will continue to be required to have fallback interfaces such as MCI unless an exemption has been obtained under Article 13 of the UK-SCA-RTS. The fallback exemption application can be found here. Under the fallback exemption, ASPSPs are required to file quarterly REP020 Report – statistics on the availability and performance of a dedicated interface. 

 It is worth noting that European ASPSPs with a fallback exemption from their Home National Competent Authority (NCA) are also allowed to be exempted by the FCA without the need for any new fallback exemption application. 

Banfico Approach 

All our clients using the MCI solution will be provided with the possibility to upgrade to our Open Banking Dedicated API solution or find another vendor. Our Open Banking Dedicated API supports all major API standards, is fully SCA compliant, available on-premise or via the cloud, and has a simple onboarding process. Also, our clients will be offered an option to cancel the existing MCI contract on a pro-rata basis. 

Reference Material

For the original literature from FCA PS21/19 on the MCI, please refer to:

  • Page 16 – Item 2.37 – Consultation Comments
  • Page 58 – Item E (2) – Commencement Date
  • Page 63. Article 31. Para3 – Updated article of SCA-RTS


Authorised Payment Institution (API): In order to become an API, the entity has to show an average monthly turnover in payment transactions over €3m. If the business provides payment initiation services (PIS) and/or account information services (AIS) it must hold adequate indemnity cover. 

Small Payment Institution (SPI): An SPI has a monthly turnover in payment transactions lower than €3m. Businesses that are registered as SPIs are not permitted to provide AIS or PIS under the Payment Services Regulations 2017 (PSRs). 

Small Electronic Money Institution (SEMI): If a business wants to issue electronic money (e-money), but it doesn’t expect to show an average turnover of €5m in outstanding e-money immediately before registration, it must be registered in the FCA as a SEMI. Businesses can also provide unrelated payment services if the average monthly turnover in payment transactions isn’t more than €3m. 

Electronic Money Institution (Authorised EMI): If a business wants to issue electronic money (e-money), it must be registered or authorised by the FCA as an EMI, in accordance with the Electronic Money Regulations 2011 (EMRs). EMIs are expected to show an average turnover of €5m in outstanding e-money immediately before registration.   

Source: Financial Conduct Authority

About Banfico

Open Banking Solution provider

Banfico is a technical solutions provider founded in 2017. Our team is formed of experts with vast experience in financial services. We have successfully delivered open banking solutions in the UK, Europe, and Brazil, and we are expanding to other parts of the globe.

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